The Ministry of Labor has published a draft amendment to the Act on the National Labor Inspectorate (PIP), which is intended to change the rules for overseeing the labor market in Poland. The government is abandoning the idea of fully imposing social security contributions on civil contracts, but instead strengthening the Inspectorate's powers, focusing on specific monitoring tools and better employee protection.
New powers of the National Labor Inspectorate
The largest and most controversial change is granting the National Labor Inspectorate (PIP) the right to convert "defectively" concluded civil law contracts, including B2B contracts, into employment contracts. According to the project's assumptions, labor inspectors, upon finding irregularities, will be authorized to issue an administrative decision, which will immediately have consequences for labor law. The decision will be preceded by an inspection of the employing entity. Following this inspection, as before, a report will be prepared, to which objections can be submitted.
Once a decision is issued, any entity that disagrees with its content will have seven days to appeal. Importantly, filing an appeal will not, as a rule, suspend the enforceability of the decision.
Twice as high sanctions
Sanctions will also change – the range of fines will be doubled, inspectors will be able to impose higher fines (up to PLN 10,000 for repeat offenders), and the maximum court fine will increase to PLN 60,000. At the same time, the Inspectorate itself is planning to strengthen its staffing and budget: employ an additional 360 people and increase funding by at least 10% from 2026.
Digitalization and inter-institutional cooperation
The National Labor Inspectorate will be making greater use of digital tools. Some inspection activities will be conducted remotely, such as online interviews, camera-assisted workplace inspections, and document exchanges via email or mail. Objections to reports will also be able to be submitted electronically, simplifying procedures for inspected entities.
The reform also envisages more efficient information exchange with other institutions, particularly the Social Insurance Institution (ZUS) and the National Revenue Administration (KAS). The National Labor Inspectorate (PIP) will immediately forward to ZUS data on decisions confirming the existence of an employment relationship, which will facilitate the enforcement of contribution obligations. Joint task forces involving the PIP, ZUS, and KAS will also allow for better targeting of entities for inspections and limiting random actions.
What else will change?
The reform is not limited to new inspection powers and higher penalties. It also includes a number of organizational solutions designed to modernize and streamline the operation of the Inspectorate:
- Annual and multi-annual inspection programmes – the Chief Labour Inspector will be obliged to prepare annual and multi-annual inspection programmes based on risk analysis in individual industries, which is intended to move away from the model of random inspections
- PIP development strategy – the obligation to develop a multi-year plan to strengthen the Inspectorate, including filling staff vacancies, implementing modern IT tools, new risk assessment methods and a training system for inspectors.
- Systems security – The Inspectorate will have to conduct an IT security audit and introduce uniform standards for control management.
- Permanent inter-institutional cooperation – the Chief Labour Inspector, the President of the Social Insurance Institution (ZUS) and the Head of the National Revenue Administration (KAS) are to establish a joint task force for risk assessment, whose task will be to coordinate activities and identify entities most exposed to irregularities.
Controversy
The National Labor Inspectorate (PIP) reform promises significant strengthening of employee protection and greater effectiveness of inspections. At the same time, it raises serious concerns – critics point out, among other things, the lack of a suspension of the enforceability of appealed PIP decisions and the very short seven-day deadline for appeals. The argument is also being raised that the existence of an employment relationship should be determined by a court, not a unilateral decision by an administrative body. The market warns that civil law contracts – which in many industries are a legitimate and legal instrument of cooperation, accepted by both parties – will become burdened with significant risks for both employers and employees.
The Labour Inspectorate itself emphasises that the reform is not intended to completely eliminate civil law contracts, and many of them are fully economically justified and will continue to be present on the labour market.
In this situation, however, companies should start preparing for the new regulations now: analyze the way they cooperate with contractors, verify which contracts may have the characteristics of an employment relationship, and consider possible changes to the employment model in order to reduce the risk of disputes and sanctions after the new regulations come into force.
This article is for informational purposes only and does not constitute legal advice.
The law is current as of September 5, 2025.
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